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On November 21, 2025 on the website of the Dutch Courts (www.rechtspraak.nl) three similar opinions of the Dutch Advocate General Wattel. All three cases concern the qualification of a Brazilian juros sobre o capital proprio (Hereinafter: JCP) for the financial years 2018 through 2020 under the Dutch-Brazilian DTA. In the English Language a JCP is referred to as “Interest on Net Equity” (Hereinafter: IoNE) or as an “Allowance for corporate equity”. One of the most interesting issues discussed in the conclusions of the Advocate General regards the legal status of the outcome of a Mutual Agreement Procedure (Hereinafter: MAP).
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The European Parliament adopted a legislative resolution of 13 November 2025 on the proposal for a Council directive on Business in Europe: Framework for Income Taxation (BEFIT). The resolution was adopted with 370 votes in favour, 160 against and 107 abstentions. In its resolution the Members of the European Parliament amongst other propose a few notable changes to the Commission’s BEFIT blueprint.
